What was hallucinated

Fabricated: Case Law | Appellant's brief cited multiple nonexistent cases to support legal arguments (nine identified fictitious authorities). Court described these as fictitious AI-generated citations. || False Quotes: Case Law | Appellant quoted language allegedly from Krumwiede to support a rule on dismissal with prejudice; the quoted language does not appear in the actual decision and the cited Krumwiede citation was incorrect. || Misrepresented: Case Law | Appellant attributed a holding concerning 'fraud upon the court' to In re Marriage of Lehr, which the court determined was a misrepresentation of that case's holding.

Sanction teardown · CA Illinois (3d), USA · 2026-04-09

Robert S. Hulvat v. Juli Gumina, STG Divorce Law, and Jennifer B. Hulvat

What happened

In CA Illinois (3d), USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Appellant's brief cited multiple nonexistent cases to support legal arguments (nine identified fictitious authorities). Court described these as fictitious AI-generated citations.
False Quotes (Case Law)

Appellant quoted language allegedly from Krumwiede to support a rule on dismissal with prejudice; the quoted language does not appear in the actual decision and the cited Krumwiede citation was incorrect.
Misrepresented (Case Law)

Appellant attributed a holding concerning 'fraud upon the court' to In re Marriage of Lehr, which the court determined was a misrepresentation of that case's holding.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary Sanction (monetary penalty: 3178 USD.)

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/1966/Hulvat_v._Gumina_USA_9_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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